Norwegian preliminary approach. Delegated act on rules for the production of renewable hydrogen from electricity

We refer to the process of drafting of a delegated act on rules for the production of renewable hydrogen from electricity. In our contribution to the consultation on the revision of the Directive on the promotion of energy from renewable sources, Norway holds that the Norwegian electricity production is close to 100 per cent renewable. A requirement for additionality in determining the renewable share of hydrogen consumption, may seriously challenge the viability of our renewable hydrogen projects. A flexible approach in line with the aim of the Directive should allow for taking into account the specificities of the Norwegian renewable power system. In addition to the calculation options established in the Directive, and the delegated act, alternative calculation methods should be accepted, subject to verification by independent third party, and subject to the approval of the independent national regulatory authority.

Needed predictability would follow from including the following wording into the preamble or the first Article of the delegated act:

‘For the calculation of the share of renewable electricity in the electricity supplied for the purposes of the Directive 2018/2001/EU Article 27 and this regulation, Member States shall refer to the two-year period before the year in which the electricity is supplied in their territory. Where electricity is used for the production of renewable fuels of non-biological origin, either directly or for the production of intermediate products, the average share of electricity from renewable sources in the country of production, as measures two years before the year in question, shall be used to determine the share of renewable energy. As an alternative to this point of departure for the calculation of renewable share, Member States may apply the counting rules in this regulation. Where adequate, alternative calculation methods may be accepted, subject to verification by independent third party, and subject to the approval of the independent national regulatory authority.’

As a country with high renewable shares in the electricity production, Norway emphasizes that it should be taken into account how different documentation methods can be combined in order to document 100 per cent renewable hydrogen production. A risk could be that the easiest and least cost solution for providing 100 per cent renewable electricity would be to use a direct connection between renewable electricity generation capacity and RFNBO production. This could result in a situation where the flexible consumption from electrolysis is not utilized to a full extent. Further, this could lead to a sub-optimal outcome and increase the costs of strengthening electricity networks and challenge security of supply for electricity.